EFTA00393653.pdf

From: Darren Indyke < To: Lesley Groff <1 Subject: Fwd: Privileged and Confidential Date: Mon, 18 Mar 2013 14:49:58 +0000 Capdeville's address and contact info is in this email chain. Call his office and ask what to use for Fed Ex. Please. Thanks. DARREN K. INDYKE DARREN K. INDYKE, PLLC 575 Lexington Avenue, 4th Floor New York, New York 10022 ************ ******* *********** ************* ****** *************** ***************** *********** The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke, PLLC. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail, and destroy this communication and all copies thereof, including all attachments. Copyright of Darren K. Indyke, PLLC - © 2011 Darren K. Indyke, PLLC —All rights reserved. Begin forwarded message: From: "Douglas Capdeville" Date: March 13, 2013 10:34:33 AM EDT To: "'Darren Indyke"' < Subject: RE: Privileged and Confidential Ok. I will work on something today and get back to you. From: Darren Indyke [mallto Sent: Wednesday, March 13, 2013 10:01 AM To: Douglas Capdeville Subject: Re: Privileged and Confidential Would rather you tell me precisely what you need Sent from my iPhone EFTA00393653 On Mar 13, 2013, at 9:38 AM, "Douglas Capdeville" < > wrote: Perfect. Do you want to draft up something short and sweet? From: Darren Indyke [mailto• Sent: Wednesday, March 13, 2013 9:35 AM To: Douglas Capdeville Subject: Re: Privileged and Confidential I am president of island grounds Sent from my iPhone On Mar 13, 2013, at 9:21 AM, "Douglas Capdeville" C Sounds like a winner. Who will be the signatory? From: Darren Indyke [mailto: Sent: Tuesday, March 12, 2013 3:52 PM To: Douglas Capdeville Subject: Privileged and Confidential > wrote: There are no formal documents establishing any relationship between Island Grounds and LSJ, LLC. LSJ, LLC was at the relevant time, the owner of the Island. Island Grounds, Inc. employed workers to perform, among other things, construction work and services on Little St. James. Island Grounds, Inc. was owned at the time by IGO Company, LLC a USVI limited liability company whose sole member was Jeffrey Epstein. Jeffrey Epstein is also the sole member of L.S.J., LLC. Bellevue, who is Mark's employee, was aware of a relationship between LSJ and Island Grounds such that he chose to sue Island Grounds when he was performing work under Mark's contract with LSJ. Probably some affidavit stating as little as possible but enough to get you where you need to be in terms of standing. DARREN K. INDYKE DARREN K. INDYKE, PLLC 575 Lexington Avenue, 4th Floor New York, New York 10022 ********************************************************************************************** The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke, PLLC. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this EFTA00393654 communication in error, please notify us immediately by return e-mail, and destroy this communication and all copies thereof, including all attachments. Copyright of Darren K. Indyke, PLLC - © 2011 Darren K. Indyke, PLLC —All rights reserved. On Mar 12, 2013, at 3:16 PM, Douglas Capdeville wrote: I always believed Mark was operating as a sole proprietorship even if though there is the word "Company" prefacing his name in the contract at issue. I will double check with the corporate records office on St. Thomas and confirm he is not a corporation. As to the second matter, he is trying to force us to reveal what the relationship is between the defendant/third party defendant, and L.S.I., other than simply a "representative". I do want to be careful that we don't leave ourselves open to dismissal for failure to allege sufficiently any matter. So, if you have any documentation establishing what the relationship is, we should have it on hand to fight the statement that Island Grounds has questionable standing to step into the shoes of L.S.J. Or perhaps an affidavit would suffice at this juncture in our opposition . Thanks. From: Darren Indyke [mailto: Sent: Tuesday, March 12, 2013 1:59 PM To: Douglas Capdeville Subject: Fwd: Bellevue v. Island Grounds, Inc. I am not sure I understand his first point about he being a business and therefore can't be sued as an individual. Am I missing something? If he is operating a sole proprietorship without using an LLC or Corp, then why is he not individually liable? Secondly, does his second point that we have not attached anything to demonstrate that we are a representative make any sense? I am not sure what you want me to respond. Both points seem silly. What specifically do you want to know. Thanks. DARREN K. INDYKE DARREN K. INDYKE, PLLC 575 Lexington Avenue, 4th Floor New York, New York 10022 ********************************************************************************************** The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke, PLLC. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this EFTA00393655 communication in error, please notify us immediately by return e-mail, and destroy this communication and all copies thereof, including all attachments. Copyright of Darren K. Indyke, PLLC - © 2011 Darren K. Indyke, PLLC —All rights reserved. Begin forwarded message: From: "Janelle Boodoosingh" < Date: March 6, 2013 4:11:24 PM EST To: "'Darren Indykem < Cc: "'Douglas Capdeville"' < Subject: Bellevue v. Island Grounds, Inc. > Enclosed please find the attached letter with enclosure regarding the above-referenced matter. Jouttelle/13aaci Office Manager Law Offices of Douglas L. Capdeville, P.C. 2107 Company Street. Lot 4 P.O. Box 224191 St. Croix, U.S. Virgin Islands 00822 EFTA00393656